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Evolve Bank & Trust: fintech partner bank, Synapse and regulators

Evolve's Open Banking business: fintech partners and accounts

Since 2017 the bank's Open Banking division has let fintech companies offer accounts, cards and payments built on Evolve: the fintech keeps the customer relationship while the bank holds the money, often in pooled for-benefit-of accounts or sub-deposit accounts placed at other banks. Partners named in filings and the bank's own materials include Affirm, Dave, Branch, Marqeta, Stripe, Mercury, Melio, EarnIn, Airwallex, B9 and Step. In 2025 Mercury announced its exit and Dave began opening new members at another bank, and in 2026 a plan to sell some programmes to Coastal Community Bank was dropped.

published
23 oct 2026
records as of
16 oct 2026
entities
142
sources
119
cite entities.csv

the questionHow does Evolve's Open Banking business work, and which fintech companies has it served?

1How the model works

analysisEvolve started its Open Banking business in 2017, offering fintech partners API banking so that they could build its banking services into their own platforms, and later added payment processing, compliance management and lending services. The Federal Reserve's 2024 order describes the strategy as offering deposit accounts and payment processing to fintech partners, which in turn offer financial products to end users. In its 2024 Investor Relations kit the bank says fintech apps can issue 'vAccounts' to users while Evolve holds the funds in its 'stored value ecosystem'; it cites principal membership of Visa and Mastercard and $8 billion of total bank and custodial assets, undated marketing figures that include custodial assets outside the balance sheet. Senators noted that the bank's assets grew from $451 million at the end of 2019 to $1.75 billion three years later. 1 2 3 4 5 6

analysisThe account terms that partners publish show how customers' money can move. Under the agreement published by Sila, the customer appoints the bank as agent to place funds at its discretion in a deposit or omnibus custody 'Sub-Deposit Account' in the bank's name, in its Trust Department or at other insured banks, with ownership recorded only in the bank's books; Dwolla's version of the terms, last updated August 1, 2021, adds that the other bank's records are in Evolve's name as agent or custodian. B9's 2026 agreement places customers in a 'Bank Deposit Custodial Program' whose sub-deposit accounts are obligations of the program banks, not of Evolve or B9. Melio holds master accounts at Evolve and other banks titled for the benefit of its customers and instructs the banks on moving the funds. 7 8 9 10

sources in this section

  1. Company statement source · src-012 identified by category only · Company statement
  2. Other source · src-004 identified by category only · Other
  3. Order to cease and desist issued upon consent: Evolve Bancorp, Inc. and Evolve Bank & Trust Board of Governors of the Federal Reserve System · 11 Jun 2024
  4. Company statement source · src-005 identified by category only · Company statement
  5. Company statement source · src-020 identified by category only · Company statement
  6. Letter from Senators Warren, Baldwin, Wyden and Fetterman to Governor Bowman about Evolve U.S. Senate Committee on Banking, Housing, and Urban Affairs · 22 Apr 2025
  7. Company statement source · src-045 identified by category only · Company statement
  8. Company statement source · src-085 identified by category only · Company statement
  9. Company statement source · src-061 identified by category only · Company statement
  10. Company statement source · src-073 identified by category only · Company statement

2Partners

analysisDave Inc. has had a Bank Services Agreement with Evolve since July 13, 2020, under which the bank issues and maintains deposit accounts and sponsors debit and ACH access while Dave keeps the ledger needed for pass-through deposit insurance. Affirm says Evolve is the single issuing bank for the Affirm Card under a loan program agreement that renews each year. Marqeta announced a partnership in 2022 for card programmes, although its 2025 report names Sutton Bank, not Evolve, as its main issuing bank. Stripe says Stripe Treasury funds are held at Evolve and Goldman Sachs Bank USA, and the fintech Arc described start-ups' funds held in treasury accounts at Evolve. Airwallex's U.S. agreement lets Evolve provide domestic payment services to Airwallex customers, Branch's Branch Account has included an Evolve deposit account since January 2020, and EarnIn's Early Pay requires a deposit account at Evolve or Lead Bank. Usio used Evolve as sponsor bank for PINless debit processing from 2018 until TransPecos Bank took over in 2023. 1 2 3 4 5 6 7 8 9 10 11 12 13

analysisThe bank's own lists changed over time. Its 2023 kit showed Branch, EarnIn, Melio, Prizepool, Sila, Stripe and Uphold; the 2024 kit showed Affirm, Airwallex, Bond, Branch, Dave, Marqeta and Melio; and the partnerships page in the retained website copy lists Airwallex, Affirm, Branch, EarnIn, Flute, Luqra, Marqeta, Mastercard, Melio, Netevia, Rain, Split Pay, Step, TabaPay, Visa and VIVA Finance, without distinguishing card networks, programme managers and fintech programmes. Its news page lists an item on Coinstar expanding a transfer-to-account service with TabaPay and Evolve. 14 15 16 17

documentedThe 'Who we power' page of the bank's 2023 Investor Relations kit shows the logos of Branch, EarnIn, Melio, Prizepool, Sila, Stripe and Uphold. 14

qualification
Logo text recognised from an image; the kit does not describe the services provided to each.

documentedThe corresponding page of the 2024 kit shows the logos of Affirm, Airwallex, Bond, Branch, Dave, Marqeta and Melio. 15

qualification
Logo text recognised from an image.

sources in this section

  1. Dave Inc. Form 10-K for the year ended December 31, 2025 U.S. Securities and Exchange Commission (EDGAR) · Mar 2026
  2. Affirm Holdings, Inc. Form 10-K for the fiscal year ended June 30, 2025 U.S. Securities and Exchange Commission (EDGAR) · Aug 2025
  3. Company statement source · src-034 identified by category only · Company statement
  4. Company statement source · src-046 identified by category only · Company statement
  5. Marqeta, Inc. Form 10-K for the year ended December 31, 2025 U.S. Securities and Exchange Commission (EDGAR) · Feb 2026
  6. Company statement source · src-076 identified by category only · Company statement
  7. Licensee record: Stripe Payments Company California Department of Financial Protection and Innovation · 16 Oct 2026
  8. Licensee record: Airwallex US, LLC California Department of Financial Protection and Innovation · 16 Oct 2026
  9. Company statement source · src-071 identified by category only · Company statement
  10. Branch Messenger, Inc. Form D notice U.S. Securities and Exchange Commission (EDGAR) · 2021
  11. CFPB complaint against Walmart Inc. and Branch Messenger, Inc. (D. Minn. No. 24-cv-4610) Consumer Financial Protection Bureau · 23 Dec 2024
  12. Company statement source · src-074 identified by category only · Company statement
  13. Usio, Inc. Form 10-K for the year ended December 31, 2025 U.S. Securities and Exchange Commission (EDGAR) · Mar 2026
  14. Company statement source · src-020 identified by category only · Company statement
  15. Company statement source · src-005 identified by category only · Company statement
  16. Company statement source · src-043 identified by category only · Company statement
  17. Company statement source · src-114 identified by category only · Company statement

3Departures and a dropped sale

analysisA fintech industry newsletter reported in February 2026 that major programmes, including Mercury and Dave, had left the bank, cutting its deposit and referral fee revenue by 66%, and that the teen app Step, the cash-advance app B9 and the middleware platform Mbanq still worked with it; Mercury had announced in March 2025 that it would move customers to Column N.A. and Choice Financial Group. A bank spokesperson told a business magazine in March 2025 that Evolve remained focused on strengthening existing relationships and exploring new ones with established fintechs. Dave's 2025 report says all new members are opened at Coastal Community Bank and that it expected substantially to finish moving existing members there by the end of 2026, though most accounts were still at Evolve. 1 2 3 4

attributedA fintech industry newsletter reported in February 2026 that major fintech programmes, including Mercury and Dave, had left Evolve, cutting its deposit and referral fee revenue by 66%, and named the teen banking app Step, the cash-advance app B9 and the middleware platform Mbanq among partners still working with the bank. An online encyclopedia records that Mercury announced in March 2025 that it would move its customers from Evolve to Column N.A. and Choice Financial Group by the end of 2025. 1 2 3

qualification
Newsletter reading of the bank's call report and of partner announcements.
response
An Evolve spokesperson told a business magazine in March 2025 that the bank remained focused on strengthening its existing relationships and exploring new opportunities with established fintechs.

analysisOn April 29, 2026 Coastal Community Bank signed a non-binding term sheet with Evolve to acquire the assets and deposits of a diverse set of its BaaS programmes, subject to due diligence, definitive agreements and regulatory approval. On Coastal's July 30, 2026 earnings call, according to a market-news summary, its chief executive said it was no longer actively pursuing the acquisition. 5 6

sources in this section

  1. Media source · src-035 identified by category only · Media
  2. Other source · src-050 identified by category only · Other
  3. Media source · src-096 identified by category only · Media
  4. Dave Inc. Form 10-K for the year ended December 31, 2025 U.S. Securities and Exchange Commission (EDGAR) · Mar 2026
  5. Coastal Financial Corporation Form 8-K (April 29, 2026) U.S. Securities and Exchange Commission (EDGAR) · 29 Apr 2026
  6. Media source · src-119 identified by category only · Media

4Disputes involving partners

analysisIn April 2025 a putative class of Dave customers sued Dave and Evolve in Los Angeles, alleging violations of the Military Lending Act and the Truth in Lending Act; after the federal court refused to dismiss the case or compel arbitration, Dave and Evolve jointly appealed to the Ninth Circuit in December 2025 and the case was stayed. These are the plaintiffs' allegations, with no ruling on the merits. In December 2024 the CFPB sued Walmart and Branch over Branch Accounts, which include an Evolve deposit account, opened for delivery drivers; Evolve is not a defendant. Senators wrote in 2025 that Evolve had also partnered with SoLo Funds and Branch, two fintechs sued by the CFPB. 1 2 3 4

documentedOn December 23, 2024 the CFPB sued Walmart Inc. and Branch Messenger, Inc. in the District of Minnesota (No. 24-cv-4610), alleging that they opened Branch Accounts, which include a deposit account at Evolve Bank & Trust, for Walmart's Spark delivery drivers without informed consent, paid their wages into them and made deceptive statements about the accounts. Evolve is not a defendant. 3

qualification
Allegations in the CFPB's complaint.

attributedThe April 2025 senators' letter states that, besides Synapse, Evolve partnered with SoLo Funds and Branch, two fintechs sued by the CFPB for predatory lending and unlawful deposit account practices respectively. 4

qualification
The senators' characterisation; the CFPB case against SoLo Funds is not in the retained record.

sources in this section

  1. Dave Inc. Form 10-K for the year ended December 31, 2025 U.S. Securities and Exchange Commission (EDGAR) · Mar 2026
  2. Court record source · src-094 identified by category only · Court record
  3. CFPB complaint against Walmart Inc. and Branch Messenger, Inc. (D. Minn. No. 24-cv-4610) Consumer Financial Protection Bureau · 23 Dec 2024
  4. Letter from Senators Warren, Baldwin, Wyden and Fetterman to Governor Bowman about Evolve U.S. Senate Committee on Banking, Housing, and Urban Affairs · 22 Apr 2025

timeline · 2020–2026

  1. Bank Services Agreement with Dave
  2. Coastal Community Bank signs a non-binding term sheet to buy BaaS programme assets and deposits

cite this dossier

DossierTwist, “Evolve Bank & Trust: fintech partner bank, Synapse and regulators”, dt.030, 23 October 2026, https://dossiertwist.com/dossiers/evolve-bank-trust/

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